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GDPR is beset with myth, rumour, and so-called experts. The amount of confusion and misinformation provided is incredibly detrimental. And this is largely because many organisations and individuals who are trying to promote their services are using fear tactics to do so.

But they’re missing the point.

We have a Data Protection Act currently in place, and Privacy and Electronic Communication Regulations to support it. Any organisation which is ignoring the current data protection legislation has every reason to panic about GDPR. Ignorance is no excuse. And they won’t be able to get away with ignoring GDPR willfully just because they consider data protection an inconvenient restriction preventing them taking unethical actions to make more money.

On the other hand, organisations who conform to the current legislation have a head-start when addressing how to comply with the new regulation.

GDPR – a simple summary

At its simplest, GDPR is a long-overdue evolution which is primarily about all organisations (whether data controllers or data processors):

putting the individual first

being held accountable for protecting that individual’s data

At the same time, GDPR addresses the vast changes to the data landscape since the original data protection legislation of the 1990s:

it takes account of technological advances – bear in mind, there was barely an internet in the early ’90s!

it seeks to protect EU citizens from misuse of their personal data wherever that data is processed

it addresses (at least in part) the disparity in data protection legislation throughout the EU and its members

GDPR increases both compliance obligations on the part of organisations, and enforcement powers on the part of the regulator.

Compliance Obligations: The principle of Accountability puts a heavy administrative burden on data controllers and data processors. Robust record-keeping in relation to all data processing is essential; evidenced decisions around data processing will be critical.

Enforcement Powers: Yes, there are massive fines for non-compliance. And yes, they will go up to £20,000,000 or 4% of global turnover. But is that really the key headline?

GDPR’s Key Message: Put the Individual First

As GDPR comes closer, individuals are going to become increasingly aware of their rights – new and old

All organisations who process personal data need to understand that individuals must be treated fairly, and have, under GDPR, greater rights than before. This means that organisations need to be transparent about their data processing activity, and take full responsibility for protecting the personal or personally identifiable data they process.

What does that mean in practice?

Tell the individuals what you intend to do with their data – and make it absolutely plain what you mean

Explain that there’s a value exchange – by all means help them understand the benefits to providing the data and allowing the processing – but don’t tell lies, and don’t mislead them

If you don’t want to tell them what you’re doing … you probably shouldn’t be doing it

If you need their consent, make sure you obtain it fairly, with simple messaging and utter clarity around precisely what it is to which they are consenting

Tell them all their rights (including the right to withdraw consent; to object to processing where relevant; to be provided with all the information you hold about them, to be forgotten, etc)

Always balance your rights as an organisation against their rights as an individual

Look out for your Reputation

Never underestimate the reputational damage caused by a data breach

The Information Commissioner, Elizabeth Denham, states clearly that, while the ICO has heavy-weight power to levy massive fines, “we intend to use those powers proportionately and judiciously”. So the ICO may issue warnings, reprimands, corrective orders and fines, but that could be the least of your worries.

Something that tends to be overlooked when talking about penalties of non-compliance is reputational damage. All the ICO’s sanctions (from warnings to fines) are published on the ICO website. And the press loves nothing more than a nice, juicy data breach.

So even if no fine is levied, reputations will suffer. At worst, customers will be lost. Shareholders will lose confidence. Revenues will decline. Board members will lose their jobs. And, to quote Denham again, “You can’t insure against that.”

When are they needed? How are they done?

Next year under the new GDPR data protection legislation, Privacy Impact Assessments will become known as Data Privacy Impact Assessments, and will be mandatory instead of merely recommended.

The ICO currently describes PIAs as “a tool which can help organisations identify the most effective way to comply with their data protection obligations and meet individuals’ expectations of privacy.”

While the soon-to-be-rechristened DPIAs will be legally required, data controllers should continue to fully embrace these opportunities to ensure that heavy fines, brand reputational damage and the associated risks of data breaches can be averted from an early stage in any planned operation.

When will a DPIA be legally required?

Organisations will be required to carry out a DPIA when data processing is “likely to result in a high risk to the rights and freedoms of individuals.” This can be during an existing or before a planned project involving data processing that comes with a risk to the rights of individuals as provided by the Data Protection Act. They can also range in scope, depending on the organisation and the scale of its project.

DPIAs will therefore be required when an organisation is planning an operation that could affect anyone’s right to privacy: broadly speaking, anyone’s right ‘to be left alone.’ DPIAs are primarily designed to allow organisations to avoid breaching an individual’s freedom to “control, edit, manage or delete information about themselves and to decide how and to what extent such information is communicated to others.” If there is a risk of any such breach, a DPIA must be followed through.

Listed below are examples of projects, varying in scale, in which the current PIA is advised – and it is safe to assume all of these examples will necessitate a DPIA after the GDPR comes into force:

A new IT system for storing and accessing personal data.

A new use of technology such as an app.

A data sharing initiative where two or more organisations (even if they are part of the same group company) seek to pool or link sets of personal data.

A proposal to identify people in a particular group or demographic and initiate a course of action.

Processing quantities of sensitive personal data

Using existing data for a new and unexpected or more intrusive purpose.

A new surveillance system (especially one which monitors members of the public) or the application of new technology to an existing system (for example adding Automatic number plate recognition capabilities to existing CCTV).

A new database which consolidates information held by separate parts of an organisation.

Legislation, policy or strategies which will impact on privacy through the collection of use of information, or through surveillance or other monitoring

How is a DPIA carried out?

There are 7 main steps that comprise a DPIA:

Identify the need for a DPIA

This will mainly involve answering ‘screening questions,’ at an early stage in a project’s development, to identify the potential impacts on individuals’ privacy. The project management should begin to think about how they can address these issues, while consulting with stakeholders.

Describe the information flows

Explain how information will be obtained, used and retained. This part of the process can identify the potential for – and help to avoid – ‘function creep’: when data ends up being processed or used unintentionally, or unforeseeably.

Identify the privacy and related risks

Compile a record of the risks to individuals in terms of possibly intrusions of data privacy as well as corporate risks or risks to the organisation in terms of regulatory action, reputational damage and loss of public trust. This involves a compliance check with the Data Protection Act and the GDPR.

Identify and evaluate the privacy solutions

With the record of risks ready, devise a number of solutions to eliminate or minimise these risks, and evaluate the costs and benefits of each approach. Consider the overall impact of each privacy solution.

Sign off and record the DPIA outcomes

Obtain appropriate sign-offs and acknowledgements throughout the organisation. A report based on the findings and conclusions of the prior steps of the DPIA should be published and accessible for consultation throughout the project.

Integrate the outcomes into the project plan

Ensure that the DPIA is implemented into the overall project plan. The DPIA should be utilised as an integral component throughout the development and execution of the project.

Consult with internal and external stakeholders as needed throughout the process

This is not a ‘step’ as such, but an ongoing commitment to stakeholders to be transparent about the process of carrying out the DPIA, and being open to consultation and the expertise and knowledge of the organisation’s various stakeholders – from colleagues to customers. The ICO explains, “data protection risks are more likely to remain unmitigated on projects which have not involved discussions with the people building a system or carrying out procedures.”

DPIAs – what are the benefits?

There are benefits to DPIAs for organisations who conduct them. Certainly there are cost benefits to be gained from knowing the risks before starting work:

cost benefits from adopting a Privacy by Design approach: knowing the risks before starting work allows issues to be fixed early, resulting in reduced development costs and delays to the schedule

risk mitigation in relation to fines and loss of sales caused by lack of customer and/or shareholder confidence

reputational benefits and trust building from being seen to consider and embed privacy issues into a programme’s design from the outset

For more information about DPIAs and how Data Compliant can help, please email dc@datacompliant.co.uk.

In light of the Royal Free NHS Trust’s mishandling of 1.6 million patients’ information for research and innovation purposes, the Information Commissioner’s Office (ICO) has asked the Trust to sign a four-point undertaking to ensure future compliance with data protection law. This requires them to:

establish a proper legal basis under the Data Protection Act for the Google DeepMind project and for any future trials;

set out how it will comply with its duty of confidence to patients in any future trial involving personal data;

commission an audit of the trial, the results of which will be shared with the Information Commissioner

The Royal Free worked with ‘DeepMind,’ Google’s recently acquired artificial intelligence technology, to develop an ‘alert, detection and diagnosis system.’ The hospital provided details of 1.6 million patients to the DeepMind division with a view to creating an app called ‘Streams’ that helps doctors detect patients at risk of acute kidney injury (AKI). The patients had not given their consent to this, and indeed did not know that their information was being shared in this way.

DeepMind is a sophisticated artificial intelligence program that offers ‘self-taught AI software’ to process and find solutions to projects that would otherwise require massive amounts of human learning and labour.

Elizabeth Denham, the Information Commissioner, stated:

“There’s no doubt the huge potential that creative use of data could have on patient care and clinical improvements, but the price of innovation does not need to be the erosion of fundamental privacy rights.”

Wetherspoons notifies email subscribers that they will be ceasing email correspondence

In a measure anticipating the General Data Protection Regulations (GDPR) coming into force next year, the popular pub chain J. D. Wetherspoons will be deleting their entire customer email database.

This may also be in response to a data breach in 2015 in which over 650,000 of the company’s customer email addresses were affected.

This ‘unexpected’ news came as Wetherspoons customers received an email on the 23rd last month explaining:

“I’m writing to inform you that we will no longer be sending our monthly customer newsletters by e-mail.

Many companies use e-mail to promote themselves, but we don’t want to take this approach – which many consider intrusive.

Our database of customers’ email addresses, including yours, will be securely deleted.”

We reported on this blog last month the fines that the ICO issued for illegal marketing offences made by Morrison’s, Flybe and Honda. It would seem that these high-profile cases are beginning to influence major companies in how they deal not only with the imminent tightening of regulations under the GDPR, but also increasing public awareness surrounding data protection law.

It has been reported by the NCC Group that fines from the ICO in 2016 would be £69m instead of the actual £880,500, if the GDPR had been in force. This would explain Wetherspoons decision.

A Wetherspoons spokesperson told Wired.com:

“We felt, on balance, that we would rather not hold even email addresses for customers. The less customer information we have, which now is almost none, then the less risk associated with data.”

The Government Digital Service (GDS) makes users change passwords after security breach

The DGS website, which allows registered users to find data published by government departments and agencies; public bodies and authorities, has asked its users to change their passwords after a publicly accessible database of usernames and emails had been discovered during a security scan.

The Information Commissioner’s Office has been notified but is yet to make an official statement on the matter.

A GDS spokeswoman told the BBC that only data.gov.uk accounts were compromised, not accounts associated with any other government website. She continued to explain that only email addresses, usernames and ‘hashed’ passwords, i.e. passwords that have been scrambled, not personal information such as names and addresses, had become accessible. Scrambled passwords are not as useful to cyber-criminals.

However, as a precaution, registered users will have to change their password when they next try to log in and were advised to change their password for other websites or services if it is the same as the one they used for the data.gov site.

There is no evidence yet to suggest that this breach has been exploited in any way.

Cyber-criminals often send emails to victims of a data breach, masquerading as service emails, in order to tease out more information, so web users ought to be careful in these circumstances and look out for phishing emails in their inboxes.

The ICO announced this week fines that the authority issued in April after a series of investigations taking place since 2015 uncovered 13 charities’ misuse of personal information.

The ICO’s online statement highlights fines ranging from £6,000 for Oxfam for processing information about people that had not been consensually provided, to £18,000 for the International Fund for Animal Welfare for numerous breaches of data protection law, including the sharing of donor information with other charities.

Government department changes name: DCMS becomes DDCMS

The government has announced that the former Department for Culture, Media and Sport (DCMS) will now be the Department for Digital, Culture, Media and Sport (DDCMS). This reflects the government’s commitment to preparing for an increasingly digitalised world.

However, the department will still be known as the DCMS in all communications.

A government statement outlines the change:

“In a move that acknowledges the way the Department’s remit has evolved, the Prime Minister and Culture Secretary Karen Bradley have agreed a departmental name change. The Department will continue to be referred to as DCMS in all communications, but is now the department for Digital, Culture, Media and Sport.”

Corrupted Ukrainian accountancy software ‘MEDoc’ is suspected to be the medium of a cyberattack on companies ranging from British ad agency WPP to Tasmanian Cadbury’s factory, with many European and American firms reporting disruption to services. Banks in Ukraine, Russian oil giant Rosneft, shipping giant Maersk, a Rotterdam port operator, Dutch global parcel service TNT and US law firm DLA Piper were among those suffering inabilities to process orders or else general computer shutdowns.

Heralded as “a recent dangerous trend” by Microsoft, this attack comes just 6 weeks after the WannaCry attack primarily affecting NHS hospitals. Both attacks appear to make use of a Windows vulnerability called ‘Eternal Blue,’ thought to have been discovered by the NSA and leaked online – although the NSA has not confirmed this. The NSA’s possible use of this vulnerability, which has served to create a model for cyber-attacks for political and criminal hackers, has been described by security experts as “a nightmare scenario.”

A BBC report suggests that given 80% of all instances of this malware were in Ukraine, and that the provided email address for the ‘ransom’ closed down quickly, the attack could be politically motivated at Ukraine or those who do business in Ukraine. Recent announcements suggest it could be related to data not money.

The malware appears to have been channelled through the automatic update system, according to security experts including the malware expert credited with ending the WannaCry attack, Marcus Hutchins. The MEDoc software would have originally begun this process legitimately, but at some point the update system released the malware into numerous companies’ computer systems.

In a blog published at the end of last week, the tech firm Google have confirmed that they will stop scanning Gmail users’ emails for the sake of accruing data to be used in personalised adverts, by the end of the year. This will put the consumer version of Gmail in line with the business edition.

Google had advertised their Gmail service by offering 1GB of ‘free’ webmail storage. However, it transpired that Google was paying for this offer by running these scans.

This recent change in tactic has been met with ‘qualified’ welcome by privacy campaigners. Executive director Dr Gus Hosein of Privacy International, the British charity who have been campaigning for regulators to intervene since they discovered the scans, stated:

When they first came up with the dangerous idea of monetising the content of our communications, Privacy International warned Google against setting the precedent of breaking the confidentiality of messages for the sake of additional income. […] Of course they can now take this decision after they have consolidated their position in the marketplace as the aggregator of nearly all the data on internet usage, aside from the other giant, Facebook.

Google faced a fairly substantial backlash on account of these scans when they were discovered, notably from Microsoft, with their series of critical ‘Gmail man’ adverts, depicting a man searching through people’s messages.

However, digital rights watchdog Big Brother Watch celebrated Google’s move, describing it as “absolutely a step in the right direction, let’s hope it encourages others to follow suit.”

UK Conservative Party under investigation for breaching data protection and election law

A Channel 4 News undercover investigation has provoked ‘serious allegations’ of data protection and election offences against the Conservative Party.

The investigation uncovered the party’s use of a market research firm based in Neath, South Wales, to make thousands of cold calls to voters in marginal seats ahead of the election this month. Call centre staff followed a ‘market research’ script, but under scrutiny this script appears to canvass for specific local Conservative candidates – in a severe breach of election law.

Despite the information commissioner Elizabeth Denham’s written warnings to all major parties before the election began, reminding them of data protection law and the illegality of such telecommunications, the Conservatives operated a fake market research company. This constitutes a breach separate to election law, and mandates the Information Commissioner’s Office to investigate.

The ICO’s statement on 23rd June reads,

The investigation has uncovered what appear to be underhand and potentially unlawful practices at the centre, in calls made on behalf of the Conservative Party. These allegations include:

Misleading calls claiming to be from an ‘independent market research company’ which does not apparently exist

MyHome Installations Ltd fined £50,000 for nuisance calls

Facing somewhat less public scrutiny and condemnation than the Conservative Party, Maidstone domestic security firm MyHome Installations has been issued a £50,000 fine by the ICO for making nuisance calls.

The people who received these calls had explicitly opted out of telephone marketing by registering their numbers with the Telephone Preference Service (TPS), the “UK’s official opt-out of telephone marketing.”

The ICO received 169 complaints from members of the public who’d received unwanted calls about electrical surveys and home security from MyHome Installations Ltd.

International Trade Secretary Liam Fox stressed that “it’s a warning to everybody, whether they are in Parliament or elsewhere that they need to do everything possible to maintain their own cyber security.”

MPs took to Twitter and social media to notify their constituents as their parliamentary email accounts were besieged by a concerted 12-hour ‘brute force’ cyberattack targeting ‘weak passwords.’

On Friday night, parliamentary officials “discovered unauthorised attempts to access accounts of parliamentary networks users.” In response, remote access to the network was cut off, meaning that MPs and aides could not access their official email accounts outside of Westminster.

Parliamentary officials have been working with the National Cyber Security Centre, part of intelligence agency GCHQ, to investigate the attempted breach and assess the potential compromise to national security.

The NCSC’s latest statement on their website, as of Saturday, reads:

The NCSC is aware of an incident and is working around the clock with the UK Parliamentary digital security team to understand what has happened and advise on the necessary mitigating actions.

It is still unclear whether the attempts were successful, or whether any confidential information in the network has been acquired. Moreover, MPs and cyber specialists can only speculate as to the identity of the cyber-attackers.

However, whether those responsible for the attack are foreign ‘state actors’ or organised criminals, the compromise to the confidentiality of private or personal information and national security details is a major risk. Security advisors have warned that the parliamentary email network is a ‘treasure trove’ of information not only for blackmailers, but also for hostile states, crime syndicates and terrorist organisations.

Many Twitter users following the story have been quick to link this attempted breach to Russian state agencies (some using the hashtag #russia), citing interference in European and American elections, as well as the cyberattack on the German Bundestag in 2015, as prior examples of similar assaults on democratic institutions. However, the relatively rudimentary nature of the ‘brute force’ attempted password hacks on Parliament on Friday contrasts, for instance, with the sophisticated attempt to install remote data monitoring software onto the German state’s computer systems two years ago, which German authorities blamed on Russian agents.

While government sources have stated that it is too early to draw conclusions regarding the fallout of the event or the perpetrators, MPs have acknowledged the extent of the threat posed by cybercrime. Tory MP for NW Leicestershire, Andrew Bridgen, stated, “if people thought our emails were not secure it would seriously undermine our constituents’ confidence and trust in approaching their MP at a time of crisis.”

Referencing the ‘WannaCry’ attack on 48 NHS hospitals only a month ago, International Trade Secretary Liam Fox said it was ‘no surprise’ that Parliament would face hacking attempts given the recent attack on our public services.

In the Queen’s Speech last week, the government outlined plans to improve data protection with a new Data Protection Bill, but this did not provide details of plans to counter threats of largescale hacking or cybercrime at home or abroad.

The government indicated, however, that they hoped the new law would help them to collaborate with former EU partners and international allies in order to confront threats to global security, threats in which cyber-conflict plays an increasingly prominent role. It may well be that these measures are following up the government’s statement in 2015 in the National Security Strategy that cyber-attacks from both organised crime and foreign intelligence agencies are one of the “most significant risks to UK interests.”

The ICO, the independent authority responsible for investigating breaches of data protection law, has fined the fourth largest supermarket chain in the UK £10,500 for sending 130,671 of their customers’ unsolicited marketing emails.

These customers had explicitly opted-out of receiving marketing emails related to their Morrisons ‘More’ loyalty card when they signed up to the scheme. In October and November 2016, Morrisons used the email addresses associated with these loyalty cards to promote various deals. This is in contravention of laws defining the misuse of personal information, which stipulate that individuals must give consent to receive personal ‘direct’ marketing via email.

‘Service emails’ versus ‘Marketing emails’

While the emails’ subject heading was ‘Your Account Details,’ the customers were told that by changing the marketing preferences on their loyalty card account, they could receive money off coupons, extra More Points and the company’s latest news.

The subject heading might suggest to the recipient that they are ‘service emails,’ which are defined under the Data Protection Act 1998 (DPA) as any email an organisation has a legal obligation to send, or an email without which an individual would be disadvantaged (for instance, a reminder for a booked train departure). But there is a fine line between a service email and a marketing email: if an email contains any brand promotion or advertising content whatsoever, it is deemed the latter under the DPA. Emails that ask for clarification on marketing preferences are still marketing emails and a misuse of personal contact data.

Morrisons explained to the ICO that the recipients of these emails had opted-in to marketing related to online groceries, but opted-out of marketing related to their loyalty cards, so emails had been sent for the ostensible purpose of qualifying marketing preferences which also included promotional content. Morrisons could not provide evidence that these customers had consented to receiving this type of email, however, and they were duly fined – although in cases such as this it is often the losses from reputational damage that businesses fear more.

Fines and reputational damage

This comes just three months after the ICO confirmed fines – for almost identical breaches of PECR – of £13,000 and £70,000 for Honda and Exeter-based airline Flybe respectively. Whereas Honda could not prove that 289,790 customers had given consent to direct e-marketing, Flybe disregarded 3.3 million addressees’ explicit wishes to not receive marketing emails.

Even a fine of £70,000 – which can currently be subject to a 20% early payment discount – for sending out emails to existing customers with some roundabout content in them for the sake of promotion, will seem charitable when the General Data Protection Regulation (GDPR) updates the PECR and DPA in 2018. Under the new regulations, misuse of data including illegal marketing risks a fine of up to €20 million or 4% of annual global turnover.

The ICO has acknowledged Honda’s belief that their emails were a means of helping their firm remain compliant with data protection law, and that the authority “recognises that companies will be reviewing how they obtain customer consent for marketing to comply with stronger data protection legislation coming into force in May 2018.”

These three cases are forewarnings of the imminent rise in stakes for not marketing in compliance with data protection law. The GDPR, an EU regulation that will demand British businesses’ compliance irrespective of Brexit, not only massively increases the monetary penalty for non-compliance, but also demands greater accountability to individuals with regard to the use and storage of their personal data.

The regulators recent actions show that companies will not be able cut legal corners under the assumption of ambiguity between general service and implicit promotional emails. And with the GDPR coming into force next year, adherence to data protection regulations is something marketing departments will need to find the time and resources to prepare for.

What a week! We’ve had another hack using log in credentials stolen from another provider (see my Camelot breach blog), hundreds of thousands of pounds worth of fines issued by the ICO for millions of unsolicited calls and text, an ‘accidental’ Brexit strategy leak and people being exploited by cyber blackmail (now called Sextortion).

ICO fines and GSMAThis week Oracle Insurance was reported by consumers to the Global System Mobile Association’s (GSMA) SPAM reporting service, which the ICO accesses. After investigation the ICO found that Oracle had sent 136,369 marketing texts where sufficient consent hadn’t been given. The ICO levied a fine of £30,000.

Similar to this Silver City Tech have been fined an explosive £100,000! The Dorset-based company denies sending any unsolicited texts, let alone 1,132,149 of them. A third party company sent the texts on behalf of Silver City Tech. However the ICO sees the third party as a postman just delivering the message – it’s the company behind the message (ie the data controller) that is held responsible. Again the company couldn’t provide any evidence of consent. After being approached by the ICO in Dec 2015 a further 1,942,182 texts were sent, resulting in Silvery City Tech being being fined £100,000. There’s a clear message here -if the ICO investigates and advises you not to do something …. it’s as well to stop!

Reporting SpamIt’s worth knowing that if you want to report SPAM, just forward the text message to 7726 (spelling out SPAM). Then you don’t need to text STOP back to the marketing company – which is always a risk as doing so validates your telephone number, and unscrupulous organisations may well then sell your number to another marketing company.

Brexit Strategy LeakAccording to Sky News, the latest victim caught carrying an unguarded document in Downing Street is thought to be Julia Dockerill who works for Conservative Party vice-chairman (international) Mark Field.lady has been papped on her way to a cabinet meeting carrying a note pad detailing notes on the Brexit strategy. Now, personally I’m conflicted on this story. With all of the papping, data breaches, hacks and data-in-transit news stories that we all hear about on a daily basis, surely the victim must know that she needs to be safer than this? Who doesn’t close their notepad after using it – especially outside Number 10? (Or is that me being fussy?) There are arguments saying that this was planned and wasn’t an accident at all. What do you think?

SextortionIf you’d asked me what sextortion was on Monday I would have looked at you blankly and thought you were speaking a different language. However on Wednesday the term was everywhere – on the radio, all over the BBC website and all over social media. If you haven’t heard about it, it’s organised criminal gangs enticing individuals (mainly young men) to perform sexual acts on a webcam. The criminals then threaten to release the footage to their friends and family unless they pay them. Police say that the number of cases that the victims have been brave enough to report has over doubled from last year.. There are victims as young as 15 although statistics show that the majority of victims fall into the 18-21 age bracket, and there have been 4 suicides this year. Police are advising not to pay anything to blackmailers and contact the police immediately. The force has arrested 40 men responsible in the Philippines.

TalkTalk and Post Office HackReports are coming in that TalkTalk and Post Office customer’s internet access has been cut after a number of routers were targeted. The Post Office have said that it has affected 100,000 of it’s customers and the problem started on Sunday. (A lot happened on Sunday, first the National Lottery, now the Post Office – is no one safe on a Sunday!?) Although it has affected a lot of people, we should thank our lucky stars we’re not in Germany where a similar hack affected an unlucky 900,000 customers.

I think we’ll all be thankful when this week ends. It just seems to be getting worse. However on a positive note it’s December now! Only 22 days until Christmas!!! (Not that I’m counting).